JET AVIATION ENGINEERING SERVICES L.P. 116 KESTREL DRIVE SPRING BRANCH, TEXAS 78070 USA

TEL: (1

- 830) 438 7486 • FAX: (1

- 830) 438 7811 www.jetaviation.com Page 1 of 7 27 September, 2010

Mr. Jayson Claar, Airframe and Cabin Safety Branch, ANM

- 115 Transport Airplane Directorate, Aircraft Certification Service, Federal Aviation Administration,

1601 Lind Ave. SW Renton, Washington 98005

- 4056

cc: Mr. Ezra Sasson, Proje ct Engineer

ANE

- 170, Special Certification Office

Subject: Amend Exemption 10133 issued to Jet Aviation Engineering Services L.P. by adding an exemption from the requirements of § 25.601 of Title 14, Code of Federal Regulations (14 CFR) for the Aft Lowe r Deck Alternating Tread Stairway.

References: 1. FAA Project no. ST5653NY

- T Boeing 747

- 400, s/n 28343, HZ

- HMI

– Saudi Arabia Head of State Aircraft, VIP Configuration.

2. FAA Exemption 10133

3. Docket number FAA

- 2010

- 0580

BACKGROUND

Boeing 747

- 468, S/N 28343 is to be modified for use as a head of state VIP airplane. The Boeing Model 747

- 468 airplane is FAA approved under Type Certificate A20WE as a large Transport Category airplane that is limited to 660 passengers or less, depending

on the interior configuration. The VIP interior configuration proposed for STC certification includes taxi, takeoff, and landing seating provisions for 72 passengers. One flight attendant only occupies the upper deck during taxi, take off, and landing. During flight nine passengers and one flight attendant can occupy the upper deck. The forward lower lobe passenger rest compartment is not occupied during taxi, takeoff, and landing. During flight 17 passengers and one flight attendant can occupy the forward lower lobe pass enger rest compartment. These aspects have already been addressed in FAA exemption 10133.

This amendment pertains to the installation of an alternating tread stair going from the Main Deck to the Aft Lower Galley Complex.JET AVIATION ENGINEERING SERVICES L.P. 116 KESTREL DRIVE SPRING BRANCH, TEXAS 78070 USA

TEL: (1

- 830) 438 7486 • FAX: (1

- 83 0) 438 7811 www.jetaviation.com Page : 2 of 7 Aft Lower Deck Alternating Tr ead Stair:

The aft lower cargo compartment is type approved as Class C. This compartment will be modified by removing the type approved cargo compartment container positioning system, cargo liner, smoke detection system and fire suppression system from th e forward bulkhead to Fuselage Station 1720 and installing a galley complex as shown below that is occupiable only during flight. The remaining area of the aft lower cargo compartment will remain in the type

- approved configuration as a Class C cargo

compa rtment.

Figure 1

Aft Lower Deck Alternating Tread Stairs Plan View

The Aft Lower Deck Galley Complex is being certified to comply with 14CFR §25.819. In addition to §25.819, compliance with other cabin safety requirements including applicable porti ons of §25.785, §25.787, §25.789, §25.791, §25.793, §25.811, §25.812, §25.851, §25.853, §25.1301, §25.1359, §25.1439, §25.1441, §25.1443, §25.1445, §25.1447, §25.1449, §25.1451, §25.1541 and §25.1561 are in addition to compliance with the applicable struct ural and electrical requirements under 14 CFR Part 25. Smoke detection and smoke penetration tests are also part of the Aft Lower Deck Galley Complex certification §25.819. This compartment is placarded not to be occupied during taxi, takeoff and landing. The door leading to the M ain Deck to this compartment is also placarded to be latched closed during taxi, takeoff and landing. A double flight attendant seat is installed between this door and Exit 4R. This compartment is restricted for occupancy by a maxi mum of four (4) flight and cabin crewmembers only. No Cargo DoorJET AVIATION ENGINEERING SERVICES L.P. 116 KESTREL DRIVE SPRING BRANCH, TEXAS 78070 USA

TEL: (1

- 830) 438 7486 • FAX: (1

- 83 0) 438 7811 www.jetaviation.com Page : 3 of 7 passengers are permitted in this area and smoking is prohibited. Placards to that effect have been installed. The latching mechanism of the door leading to the Aft Lower Deck Alternating Tread Stair s complies with §25.783(j), Amendment 25

- 54. The evacuation routes, EXIT signage, the operation of the secondary escape hatch and evacuating a 95th percentile male incapacitated occupant were satisfactorily demonstrated through

both exits on 14

- July

- 10 usi ng the same criteria as specified in Exemption 10133 for the Forward Lower Lobe Passenger Rest Compartment and with the FAA observing.

Figure 2 Aft Lower Deck Alternating Tread Stairs Photo (Aft Handrail removed for maintenance

– Image annotated for v isual reference)JET AVIATION ENGINEERING SERVICES L.P. 116 KESTREL DRIVE SPRING BRANCH, TEXAS 78070 USA

TEL: (1

- 830) 438 7486 • FAX: (1

- 83 0) 438 7811 www.jetaviation.com Page : 4 of 7 The Aft Lower Deck Alternating Tread Stairs consist of 8 alternating stair steps. The steps are slightly shallower than those on the Forward Lower Deck Alternating Tread Stair already covered by this exemption. With direct FAA partic ipation, the Aft Lower Deck Alternating Tread Stairs were evaluated as part of the FAA interior compliance evaluation for the airplane interior. That compliance evaluation included evaluations of the nine (9) proposed limitations listed in the Basis For Ex emption section below. The emergency lighting illumination measurements and the audio test of the PA system remain to be completed. Although the Aft Lower Deck Alternating Tread Stairs were found in general to be satisfactory and posed no inherent hazards to occupant safety, they were considered to be sufficiently unusual to require additional FAA scrutiny.

DISCUSSION

14CFR Part 25 of the Federal Aviation Regulations governs design certification of Transport Category aircraft. The primary intent of thes e regulations, as written, are to be certain that Aircraft Manufacturers provide for the appropriate design features in their respective aircraft to meet the standards necessary to protect the traveling public. Clearly, there is a requirement “in the publ ic interest” and in the interest of safety to provide regulatory guidelines for certification. However, it is also very clear these regulations are intended to regulate the certification of “commercial” aircraft, which are ‘for hire’ to the general public

.

While the greatest majority of these regulations represent a common sense inclusion for any aircraft regardless of its intended use, a few are obviously intended to regulate situations that are specific to an airline, or for hire operation. When a Tran sport Category aircraft is operated under CFR Part 91 and 91.501 and/or CFR Part 125, some of the 14 CFR 25 rules have acceptance criteria that are inappropriate, or are not compatible with this type of operation and the intended use of the aircraft.

Tran sport Category Aircraft intended for Private use, whether originally designed for private use or public, revenue

- type operations and then utilized under CFR Part 91 or CFR Part 125, are used for personal (corporate) non

- revenue operations, which represent significant operational differences from the typical revenue operation. The differences represented in these private operations can best be described as follows:

1. Operation is limited to the private use of an individual(s), Corporation, or

Government a nd does not include public

- for hire

- operations.

2. Passenger capacity of the aircraft is significantly less than an equivalent aircraft in commercial operations. Typically, the capacity is less than 30% of that found in an airline configuration.

3. Flight and Cabin Crews are typically highly trained, and far more familiar with the individual aircraft they are operating, since it is normally the primary aircraft on which they perform their duties.JET AVIATION ENGINEERING SERVICES L.P. 116 KESTREL DRIVE SPRING BRANCH, TEXAS 78070 USA

TEL: (1

- 830) 438 7486 • FAX: (1

- 83 0) 438 7811 www.jetaviation.com Page : 5 of 7 4. Security is extremely high in terms of access to the aircraft while on the ground and with respect to individuals boarding the aircraft.

5. Passengers on these aircraft are typically repeat passengers, and represent corporate employees or individual owners and family members. As a result, the

passen gers are far more familiar with the layout of the individual aircraft and the associated emergency equipment and exits.

6. Custom interior layouts, furnishings, fixtures, furniture, cabinets, galleys, etc. are more representative of ‘Board Room’ type fur nishings, than airline style interiors. Seat Pitch and Aisle Widths are typically substantially more spacious than an

airline interior.

PETITION

We respectfully request the FAA to issue an amendment to Exemption 10133 for the subject aircraft to 14 CFR §25.601, Amendment 25

- 0 by adding the Aft Lower Deck Alternating Tread Stairway.

This Petition is required due to the Kingdom of Saudi Arabia having determined these exemptions are necessary for the mission requirements for their head of state air transp ortation.

BASIS FOR EXEMPTION

The aircraft that is the subject of this petition is a 747

- 400 aircraft. The aircraft is currently at the modification facility, Jet Aviation in Basel, Switzerland. It is a privately owned aircraft being modified with a head of state type interior.

In addition, Jet Aviation proposes the following conditions as part of the type design of the Aft Lower Deck Alternating Tread Stairway be added to Exemption 10133:

Aft Lower Deck Alternating Tread Stair : The Aft Lower Deck A lternating Tread Stair must meet the following requirements:

1. The stairway must be straight with adequate step size to comfortably stand on both feet. Handrails on each side of the stairway must allow support at any position on the stairs and allow peo ple to steady themselves during foreseeable conditions, including, but not limited to, moderate turbulence in flight. The
handrails must be constructed, so that there will be no obstruction on them which will cause the user to release his/her grip on the h andrail or will hinder the continuous movement of the hands along the handrail. Handrails must be terminated in a manner that will not obstruct pedestrian travel or create a hazard. Adequacy of the design must be demonstrated by using persons representativ e of the 5 percent female and the 95 percent male.JET AVIATION ENGINEERING SERVICES L.P. 116 KESTREL DRIVE SPRING BRANCH, TEXAS 78070 USA

TEL: (1

- 830) 438 7486 • FAX: (1

- 83 0) 438 7811 www.jetaviation.com Page : 6 of 7 2. General illumination must be provided so that, when measured along the centerlines of each tread of the stairway or ladder, the illumination is not less

than 0.05 foot

- candle. In normal operation, th e general illumination level must not

be less than 0.05 foot

- candles. The assessment must be done under day light and dark of night conditions.

3. The stairway must accommodate the carriage of an incapacitated person from

the lower lobe to the main deck. The crewmember procedures for such carriage

must be established.

4. The stairway must be designed such that evacuees can achieve an adequate rate for going up under probable emergency conditions, including a condition in which a person falls or is incap acitated while on a stairway.

5. The stairway and ladder ends must be indicated by an exit sign visible to crewmembers when in the stairway. This exit sign must meet the requirements of §25.812(b)(1)(ii).

6. The public address system must be intelligi ble in the stairway during flight.

8. "No smoking" and "return to seat" signs must be installed and must be visible in the stairway both going up and down and at the stairway entrances.

9. Cabin crew procedures and positions must be established to mana ge the use of the stairs in flight under both normal and emergency situations. This may require that cabin crewmembers have specific dedicated duties for the management of the stairs during emergency and precautionary evacuations.

10. It should not be ha zardous for crewmembers or passengers who are returning to their seats to use the stairway during moderate turbulence.

11. Access to the stairway will be secured when the lower lobe galley is not to be occupied.

IN THE PUBLIC INTEREST

- The approval of this Petition to amend Exemption 10133 would demonstrate the FAA’s willingness to deal with the issues involved with this Exemption, and would be in the Public Interest for the following reasons:

There is no degradation of safety involved with this reques t and therefore no detrimental impact to the public at large; and

1. Given the proliferation of Executive Configured Transport Category Aircraft currently taking place, and anticipated in the near future, this type of exemption

will enable US manufacture rs of transport category aircraft greater flexibility to effectively compete in this expanding market; and